Power Generation, Transmission & Distribution 2026 Comparisons

Romania’s electricity sector follows the EU unbundling model and is regulated mainly by Electricity and Natural Gas Law No 123/2012, together with secondary legislation issued by the National Energy Regulatory Authority (ANRE). The market is structured around separate activities: generation, storage, transmission, distribution, supply and trading. Generation and storage are open to private investment and are carried out by both state-owned companies and private operators. This is also the area where most recent investment activity has been seen, particularly in photovoltaic, wind and battery energy storage projects. In practice, developers and investors must look beyond the energy licence itself, as projects usually depend on land rights, zoning, construction permits, grid connection, environmental approvals, financing arrangements and, increasingly, power purchase agreements. Transmission is a regulated natural monopoly operated by C.N.T.E.E. Transelectrica SA, the Romanian transmission and system operator, in which the Romanian State remains the majority shareholder. Transelectrica operates and develops the national transmission grid and is responsible for system security, balancing and cross-border interconnection. Distribution is also a regulated network activity and is carried out under concession arrangements for defined geographical areas, where distribution operators are licensed and regulated by ANRE, including in relation to tariffs, service standards, network access and investment obligations. Supply is a competitive activity where licensed suppliers may sell electricity to final consumers throughout Romania, and consumers are generally free to choose and change their supplier under the applicable market rules.

The Romanian electricity sector includes both state-controlled and privately owned operators, where, on the generation side, the principal state-controlled companies include Hidroelectrica, the largest hydropower producer in Romania; Nuclearelectrica, which operates the Cernavoda nuclear power plant; and Complexul Energetic Oltenia, which remains relevant for coal-based generation during the transition period. Other important producers include OMV Petrom, through the Brazi gas-fired power plant, as well as private and international investors active in renewable generation, including PPC Renewables, ENGIE, Econergy, Greenvolt, Premier Energy and other developers of photovoltaic, wind and storage projects. Transmission is operated by C.N.T.E.E. Transelectrica SA, the national transmission and system operator, where the Romanian State remains the majority shareholder, while the company is listed on the Bucharest Stock Exchange. Distribution is carried out by licensed operators in defined concession areas, the main distribution operators being Rețele Electrice Romania, part of PPC Group, Distribuție Energie Electrică Romania, part of Electrica Group, Delgaz Grid, part of E.ON Group, and Distribuție Energie Oltenia. The supply market is competitive and includes both state-controlled and privately owned suppliers, where the main suppliers to end consumers include Hidroelectrica, Electrica Furnizare, PPC Energie and PPC Energie Muntenia, E.ON Energie Romania, ENGIE Romania and Premier Energy, alongside several other licensed suppliers active in the commercial, industrial and prosumer-related segments.

Foreign investment in the Romanian power sector is generally permitted, and there are no broad foreign ownership restrictions applying specifically to electricity generation, storage, supply or trading. In practice, however, acquisitions and investments in energy projects may be subject to foreign direct investment screening, as energy infrastructure, storage and certain technologies are treated as sensitive from a national security and public order perspective. The Romanian FDI regime is mainly governed by Government Emergency Ordinance No 46/2022, as amended, implementing Regulation (EU) 2019/452, meaning that investments exceeding EUR5 million may require prior clearance if they concern sensitive sectors. Investments below this threshold may also be reviewed where they may affect national security, public order or projects or programmes of EU interest. The filing is made before implementation and is reviewed by the Commission for the Examination of Direct Investments (CEISD), where a transaction may be cleared, cleared subject to conditions, or rejected. In energy matters, conditions may relate to continuity of strategic activities, access to sensitive information, protection of critical infrastructure, cybersecurity, supply security or subsequent changes of control, while foreign investors benefit from the general protections available under Romanian and EU law, including protection of private property, access to domestic courts and international arbitration.

Sales of power industry assets or businesses are generally permitted in Romania, but transactions must be assessed from a corporate, regulatory, competition and foreign investment perspective under the framework of Electricity and Natural Gas Law No 123/2012, Companies Law No 31/1990, the Civil Code, Competition Law No 21/1996, the FDI screening legislation and the secondary rules issued by ANRE. Share deals, asset deals and mergers involving generation, storage, supply or trading businesses are usually possible, subject to the transferability of the relevant project rights, permits, grid connection arrangements, land rights, financing documents and commercial contracts. Energy licences are not treated as freely transferable assets, and the buyer must either hold or obtain the required licence, or secure the necessary ANRE approvals or registrations, depending on the structure of the transaction. Where turnover thresholds are met, the transaction must be notified to the Romanian Competition Council before completion, and energy transactions may also require FDI clearance, particularly where the target owns generation assets, storage facilities, grid infrastructure or other strategic assets. In non-problematic cases, merger control and FDI approvals are commonly dealt with as conditions precedent, with timelines depending on the completeness of the filing and the complexity of the review. In regulated activities, the acquirer must be able to meet the technical, financial and organisational conditions required for licensing and continued operation, with transmission and distribution assets being significantly more restricted due to their concession-based infrastructure.

Romania does not have a single authority responsible for all aspects of electricity sector planning and development, these responsibilities being shared among several institutions, primarily the Ministry of Energy, the National Energy Regulatory Authority (ANRE) and C.N.T.E.E. Transelectrica SA, the national transmission and system operator. The Ministry of Energy is responsible for energy policy, long-term strategic planning and the implementation of national and European energy objectives, playing a central role in the development of policies relating to security of supply, decarbonisation, renewable energy deployment and energy infrastructure investments. Transelectrica is responsible for operating, maintaining and developing the national transmission network and for ensuring the security and reliability of the electricity system, preparing transmission development plans, managing system balancing and assessing network adequacy and connection capacity. ANRE regulates the electricity market and network activities, approves transmission and distribution development plans and oversees compliance with licensing and regulatory requirements, while public authorities shape the future generation mix through renewable energy support schemes and the contracts for difference framework.

The past year has brought several significant regulatory developments for the Romanian power sector, particularly in relation to renewable energy, energy storage, and project development. One of the most important developments has been the continued implementation of the contracts for difference (CfD) support mechanism, designed to facilitate investment in large-scale renewable energy projects and support Romania’s decarbonisation objectives. The framework has moved from a legislative initiative to an operational support scheme, with auction rounds launched for new renewable generation capacity. Another important change concerns the regulatory treatment of energy storage, where recent legislative and regulatory amendments have further integrated storage activities into the electricity market framework and removed certain regulatory barriers that previously affected the economic viability of battery energy storage projects. In addition, ANRE adopted a new licensing and permitting framework for the electricity sector, replacing the previous regime and introducing updated rules regarding licensing procedures, storage activities, aggregation and project commissioning.

Several policy initiatives are expected to have a material impact on the Romanian power sector, the most relevant being the Energy Strategy of Romania for 2025–35, with an outlook to 2050, which sets the direction for security of supply, decarbonisation, renewable energy, nuclear energy, storage, grid development and regional interconnection. The strategy is intended to guide future legislation, public investment and support schemes in the sector, while Romania is also continuing the implementation of the contracts for difference framework for renewable energy projects. Following the first auction rounds, further measures are expected to support the financing and delivery of new wind and solar generation capacity. Offshore wind is another area of focus, since Romania adopted a dedicated offshore wind law in 2024, and the next material step will be the secondary legislation and procedures required for concessioning, permitting, grid connection and development of Black Sea offshore wind projects, alongside public authority measures aimed at accelerating grid investments and integrating storage capacity.

A distinctive feature of the Romanian power sector is the combination of a relatively diversified generation mix and a rapidly expanding renewable energy pipeline, where Romania benefits from significant hydro and nuclear generation, while also attracting substantial private investment in photovoltaic, wind and battery energy storage projects. At the same time, the market is shaped by practical constraints that are particularly relevant for investors, meaning that grid connection capacity, land rights, zoning, removal of land from agricultural use, environmental permitting and project bankability are often as important as the energy regulatory framework itself, making Romanian power projects highly multidisciplinary from a legal perspective. Another specific feature is the renewed focus on strategic energy projects, including new renewable capacity supported by contracts for difference, the development of storage, grid reinforcement, nuclear projects and the potential development of offshore wind in the Black Sea, where execution risk and regulatory coordination remain critical.

Romania has a competitive wholesale electricity market, organised mainly around trading platforms operated by OPCOM, the Romanian electricity and gas market operator. Wholesale electricity is traded through several market segments, including the day-ahead market, the intraday market, centralised bilateral contract markets and the balancing market, where prices are generally formed through competitive offers and bids rather than direct price regulation, although exceptional intervention measures may apply in periods of market stress. Romania operates an energy-only market and does not currently have a fully developed capacity market comparable to those in certain other European jurisdictions, while system balancing and ancillary services are managed by Transelectrica, the transmission and system operator, under the applicable market rules. The Romanian market does not use nodal pricing, functioning as a bidding zone within the European internal electricity market, with prices determined at market level and congestion managed through the applicable network and cross-border capacity allocation mechanisms. High-load consumers, including data centres and large industrial consumers, are generally treated under the standard regulatory framework applicable to final consumers, their key practical issues usually being grid connection capacity, timing of connection works, network reinforcement costs, electricity sourcing and contractual arrangements, including bilateral supply contracts and corporate PPAs.

Electricity imports and exports are permitted and form an important part of Romania’s participation in the European internal electricity market, as Romania is interconnected with Hungary, Bulgaria, Serbia, Ukraine and the Republic of Moldova through a number of cross-border transmission lines operated by Transelectrica and neighbouring transmission system operators. Cross-border electricity trading is carried out within the framework of EU market coupling mechanisms and the applicable network codes. Access to interconnection capacity is generally obtained through market-based allocation mechanisms rather than through individual governmental approvals, and participants engaging in cross-border trading must comply with the applicable licensing, balancing and market participation requirements. Imports and exports occur regularly depending on market conditions, generation availability, renewable output, network constraints and regional price signals, meaning Romania may act either as a net importer or a net exporter depending on demand levels and the availability of domestic generation resources. Electricity imported into Romania is generally priced through the coupled European market mechanisms and is reflected in the wholesale market price formation process, while exported electricity is priced according to the market conditions prevailing in the relevant destination bidding zones.

Romania benefits from a relatively diversified electricity generation mix compared to many other jurisdictions in the region, where hydropower remains one of the most important sources of electricity generation, alongside nuclear energy produced at the Cernavodă nuclear power plant. Natural gas-fired generation also plays a significant role in the system, while coal-fired generation continues to contribute to supply, although its share is expected to decrease over time as part of the energy transition process. Renewable energy sources have gained increasing importance in recent years, wind generation representing a significant component of the renewable mix, particularly due to the development of projects in the Dobrogea region, while solar generation has experienced substantial growth following a new wave of investments in utility-scale and distributed generation projects. The share of battery energy storage remains limited but is expected to increase significantly as new projects are developed and integrated into the electricity system.

Romanian law does not impose a general fixed market concentration cap, such as a maximum percentage of electricity supply that may be controlled by a single undertaking, meaning market concentration is mainly controlled through general competition law, merger control rules and sector-specific energy regulation. The principal framework consists of Competition Law No 21/1996, Electricity and Natural Gas Law No 123/2012, the EU and Romanian merger control rules, REMIT and the secondary regulations issued by ANRE. The Romanian Competition Council is the main authority responsible for assessing mergers, acquisitions and anti-competitive conduct, including abuse of dominance, restrictive agreements and transactions that may significantly impede effective competition. Where the applicable turnover thresholds are met, transactions must be notified to the Competition Council before implementation, and the authority may clear a transaction unconditionally, approve it subject to commitments, or prohibit it where competition concerns cannot be addressed. ANRE also has oversight over licensed electricity activities and market conduct, particularly in relation to wholesale market transparency, compliance with license conditions and REMIT obligations, where non-compliance may trigger administrative fines, remedies, or license restrictions.

The Romanian electricity market is subject to both competition law enforcement and sector-specific market monitoring under the legal framework of Competition Law No 21/1996, Articles 101 and 102 of the Treaty on the Functioning of the European Union, Regulation (EU) No 1227/2011 on wholesale energy market integrity and transparency (REMIT), Electricity and Natural Gas Law No 123/2012 and the related secondary regulations. The Romanian Competition Council is the primary authority responsible for investigating anti-competitive agreements, abuse of dominance and merger control matters, while in the energy sector, ANRE also exercises supervisory powers in relation to licensed activities and market conduct, REMIT compliance being monitored within the applicable European regulatory framework. The Competition Council has broad investigative powers, including the right to request information and documents, conduct inspections at business premises, review electronic records and interview relevant individuals, meaning it may initiate investigations on its own initiative, following complaints or because of information received from other authorities. Where anti-competitive conduct is established, the Competition Council may impose significant administrative fines, behavioural remedies or other corrective measures, and infringements of REMIT obligations or energy-sector regulations may trigger sanctions imposed by ANRE, subject to judicial review before the competent courts

The construction and operation of electricity generation facilities in Romania are governed by a combination of energy, construction, environmental and land-use legislation, where the principal legal framework is set out in Electricity and Natural Gas Law No 123/2012, which regulates electricity generation activities, licensing requirements and the operation of generation facilities. Additional sector-specific rules are issued by the National Energy Regulatory Authority (ANRE), including regulations concerning licensing, grid connection and market participation. Depending on the nature and location of the project, developers must also comply with construction, urban planning and environmental legislation, including Law No 50/1991 on construction permitting, Law No 350/2001 on territorial planning and urbanism, Government Emergency Ordinance No 195/2005 on environmental protection and the legislation governing environmental impact assessment procedures. Other regulatory requirements may arise in connection with land rights, forestry, agricultural land, cultural heritage, water management, aviation restrictions and protected natural areas, meaning that, in practice, the legal framework applicable to a generation project depends heavily on the technology involved, the location of the facility, and the characteristics of the land and infrastructure required for its development and operation.

The development of a commercial generation facility typically involves a combination of land-use, environmental, construction and energy-sector approvals, where developers generally need to secure land rights, urban planning documentation, environmental approvals, grid connection documentation, a building permit and the relevant ANRE authorisations and licences. Projects are usually initiated through the zoning and planning process, followed by environmental screening and permitting, where the competent environmental authority may require an environmental impact assessment, an appropriate assessment for Natura 2000 protected areas or other specialised studies, with public consultation forming part of the environmental permitting process where interested persons may submit observations or challenge decisions, and with public hearings being required in cases where a full environmental impact assessment is carried out. Grid connection is a critical element of project development, and requires obtaining the technical connection approval and, subsequently, concluding the connection arrangements with the relevant network operator, while ANRE remains responsible for issuing the regulatory approvals required for electricity generation activities, including establishment authorisations and operating licences, meaning that a generation facility becomes operational only after the developer has obtained all sector-specific permits and licences required under the applicable legal framework.

Approvals issued in connection with the development and operation of generation facilities typically contain conditions relating to compliance with environmental, construction, health and safety, technical and grid connection requirements, including obligations regarding implementation timelines, mitigation measures, reporting requirements, operation within approved technical parameters and compliance with the conditions imposed during the environmental assessment process. Environmental permits and approvals often require the implementation of specific environmental protection measures, monitoring programmes and reporting obligations, while construction-related approvals generally require compliance with the approved technical documentation and applicable building regulations, and energy-sector authorisations issued by ANRE include conditions relating to technical capability, operational standards and compliance with licensing requirements. Where a developer wishes to amend an approved project or modify a condition attached to an approval, the relevant authority must generally be notified and, depending on the nature of the change, an amendment procedure may be required, meaning that material modifications such as changes to the technical characteristics, capacity, location or environmental footprint of a project may trigger additional reviews or the need to obtain revised permits, approvals or licences, whereas less significant changes can often be addressed through simpler amendment procedures before the competent authority without requiring the entire approval process to be repeated.

As a rule, developers of electricity generation facilities do not benefit from broad eminent domain or expropriation powers for the acquisition of land required for their projects, meaning that project developers must secure the necessary surface rights through private arrangements with landowners or through rights granted by public authorities where publicly owned land is involved. In practice, land rights are commonly secured through ownership, superficies rights, lease agreements, concession arrangements or other rights recognised under Romanian law, where the selected structure usually depends on the nature of the project, the characteristics of the land and financing requirements. Where privately owned land is required, compensation is determined by agreement between the parties, meaning the amount is generally market-driven and depends on factors such as location, land category, duration of the rights granted, and the extent of the restrictions imposed on the landowner. Expropriation is generally available only for projects declared to be of public utility and is carried out by the competent public authorities in accordance with the applicable legal framework, where fair and prior compensation must be paid to the affected owners, who can challenge the value of the compensation before the courts where they consider that the amount offered does not adequately reflect the value of the property or the rights affected, while generation projects also frequently require easements, access rights and rights relating to connection infrastructure, which are usually obtained through contractual arrangements or specific statutory mechanisms.

The decommissioning of a generation facility is subject to the applicable energy, environmental, construction and land-use legislation, meaning that, depending on the technology involved, operators may be required to dismantle the facility, restore the site and comply with any environmental remediation obligations imposed by the competent authorities. Environmental permits and other project-specific approvals may contain explicit decommissioning requirements, including obligations relating to waste management, recycling, site restoration and monitoring, while additional requirements may apply to facilities located in protected areas or subject to specific environmental conditions. Romanian law does not generally impose a uniform obligation to establish a dedicated decommissioning fund for all generation facilities throughout their operational life, but specific obligations may arise under sector-specific legislation, financing arrangements, concession agreements, environmental permits or support schemes, meaning that lenders and investors increasingly require developers to address decommissioning costs and end-of-life obligations as part of early project planning and risk allocation.

The ownership, construction and operation of transmission facilities are primarily governed by Electricity and Natural Gas Law No 123/2012 and the secondary regulations issued by ANRE, alongside additional requirements arising under construction, urban planning, environmental protection and land-use legislation. Transmission activities are carried out by Transelectrica as the Romanian transmission and system operator, and the development of new transmission infrastructure is subject to regulatory oversight, forming an integral part of the transmission network development planning process. Environmental reviews are required depending on the characteristics and location of the project, meaning that transmission projects are commonly subject to environmental screening procedures and, where applicable, full environmental impact assessments, Natura 2000 assessments or other specialised technical studies.

The construction of transmission facilities requires a combination of planning, environmental, construction and regulatory approvals, where developers must obtain urban planning documentation, environmental approvals, land rights, construction permits and the relevant sector-specific authorisations. Environmental authorities determine whether a project is subject to environmental impact assessment procedures, where public participation forms a mandatory part of the environmental permitting process, and public consultations or hearings may be required where a detailed environmental assessment is carried out. ANRE regulates transmission activities and approves the relevant regulatory framework, but permitting powers remain divided among the competent authorities, including environmental, construction and local authorities, meaning that no single authority is solely responsible for issuing all approvals required for the development of transmission infrastructure.

Approvals relating to transmission infrastructure commonly include conditions concerning technical standards, environmental protection measures, construction requirements, operational safety, land use and compliance with the applicable regulatory framework. Environmental approvals frequently impose strict monitoring, reporting and mitigation obligations, while construction permits require full compliance with the approved technical documentation and applicable building regulations, with additional obligations frequently arising from grid operation and system security requirements. Where project parameters change, the relevant authority must generally be notified, and an amendment procedure may be required, meaning that material modifications may trigger supplementary reviews or the need to obtain revised permits or approvals, while minor changes can often be addressed through simpler administrative amendment procedures.

Unlike generation projects, transmission infrastructure may benefit from specific statutory rights intended to facilitate the development of strategic network assets, as electricity legislation grants certain rights of access, use, easement and servitude over land for the construction, operation and maintenance of electricity networks. Where voluntary arrangements cannot be reached, expropriation mechanisms may be available for projects officially declared to be of public utility and carried out in accordance with the applicable legal framework, compensation being generally payable for the rights affected or for any losses caused by the exercise of statutory rights. The amount of compensation is determined either by agreement between the parties or, in the absence of agreement, in accordance with the procedures established by law and subject to subsequent judicial review.

Electricity transmission is treated as a regulated natural monopoly in Romania, where transmission services are provided exclusively by C.N.T.E.E. Transelectrica SA, which acts as the national transmission and system operator. Transelectrica has the exclusive responsibility for operating, maintaining and developing the national transmission network, a position deriving from Electricity and Natural Gas Law No 123/2012, the applicable licensing framework and the formal designation of Transelectrica as transmission system operator. As a result, competing entities are generally not permitted to establish parallel transmission systems for the purpose of providing transmission services within the national transmission network.

Transmission tariffs and the principal terms of service are strictly regulated by ANRE, the regulator establishing the tariff methodology and approving the regulated charges applicable to transmission services. Tariffs are determined based on regulatory principles intended to ensure cost recovery, operational efficiency, network reliability and non-discriminatory access to the transmission system, where the applicable methodologies consider authorised revenues, investment requirements and other regulatory parameters established by ANRE, and the terms and conditions governing access to and use of the transmission network are set out in the applicable legislation, network codes and regulatory decisions.

Transmission services are provided on an open-access and non-discriminatory basis in accordance with Romanian and European electricity market legislation, meaning that, subject to compliance with the applicable technical, operational and commercial requirements, eligible users are entitled to request access to the transmission system for the delivery or receipt of electricity. Access rights are governed by Electricity and Natural Gas Law No 123/2012, the applicable network codes and the regulatory framework administered by ANRE, forcing Transelectrica to apply transparent and non-discriminatory conditions to network users. Once access has been granted in accordance with the applicable rules, users benefit from the rights and obligations established under the relevant connection, access and system operation arrangements.

The construction and operation of electricity distribution facilities are governed primarily by Electricity and Natural Gas Law No 123/2012, the secondary regulations issued by ANRE and the general legislation applicable to construction, urban planning, environmental protection and land use. Additional requirements may apply to storage facilities, smart grids and microgrids depending on their technical configuration and regulatory classification, while environmental reviews may be required depending on the location, scale and specific characteristics of the project.

The development of distribution facilities requires a combination of planning, environmental, construction and sector-specific approvals, where depending on the project, developers must obtain urban planning documentation, environmental approvals, land rights, construction permits and the relevant ANRE authorisations. Public participation may form part of the environmental permitting process where a detailed environmental assessment is required, meaning that public consultations and, in certain cases, public hearings may be organised by the competent environmental authorities. ANRE regulates distribution activities but does not issue all approvals required for the construction of distribution infrastructure, as permitting powers remain divided among the competent authorities, and timelines vary depending on project complexity, location and environmental requirements, commonly ranging from several months to more than one year for larger projects.

Approvals commonly include conditions relating to technical standards, environmental compliance, operational safety, construction requirements, service quality obligations and compliance with the applicable regulatory framework. Where project parameters are modified, the relevant authority must generally be notified, and an amendment procedure may be required, meaning that material changes may trigger additional reviews or revised approvals, while minor modifications can often be addressed through administrative amendment procedures.

Distribution operators may benefit from statutory rights of access, use, easement and servitude over land for the construction, operation and maintenance of distribution networks. Where projects qualify as public utility works, expropriation mechanisms may be available in accordance with the applicable legal framework, compensation being generally payable for the rights affected or for losses suffered by the landowner, and the amount is determined either by agreement between the parties or in accordance with the procedures established by law, subject to judicial review.

Electricity distribution is a regulated monopoly activity carried out within defined geographical concession areas, where licensed distribution operators hold exclusive rights and obligations in their respective territories under the concession and licensing framework established by Electricity and Natural Gas Law No 123/2012 and the regulations issued by ANRE. As a result, competing distribution networks generally cannot be developed within the same concession area for the purpose of providing public distribution services.

Distribution tariffs and the principal terms and conditions of service are regulated by ANRE under regulated methodologies designed to ensure cost recovery, network reliability, investment incentives and non-discriminatory treatment of users. The methodology is based on a regulated revenue framework that considers operating costs, capital investments, efficiency targets and other regulatory parameters, forcing distribution operators to provide services under transparent and non-discriminatory conditions. ANRE decisions may generally be challenged before the competent courts in accordance with administrative law principles; consumers and network users may also submit formal complaints to the relevant operator and, where appropriate, to ANRE regarding the application of tariffs or service conditions.